ISMAIL, C.J.

These are appeals against the order of the Board of Revenue (Commercial Taxes) dated 17th December, 1979, suo motu revising the orders of the Appellate Assistant Commissioner, Pollachi, concerning two assessment years 1972-73 and 1973-74. The appellant claimed exemption in respect of the turnover of the timber produce on the ground that they were agricultural produce and not commercial produce and they were essentially planters and in order to develop the plantation they cut the standing trees and sold them. The finding recorded by the Board of Revenue is this :

"The facts are not denied. It is true that after clearing the area of the forest growth the assessee had intended to raise plantation crops in the area. However, it is observed that they have registered themselves as dealers. Though the ultimate object of the assessee was to grow coffee, tea or cardamom, the motive to do business in logs and firewood is clearly discernible. After cutting the trees which had grown spontaneously on the land they had transported them to a saw mill, had them sawn into suitable sizes of logs and sold the sized logs locally and in inter-State trade. For this purpose they ha